Transfer Pricing in Cost Contribution Arrangements

Abstract:     
Cost contribution arrangements (CCAs) and Cost sharing agreements (CCAs) belong to the tools of modern finance management. Costs spend by associated enterprises on developing producing or obtaining assets, services or rights (in general - benefits) are used for tax optimizing too. The main purpose of joint research and development, producing or obtaining benefits is to lower these costs as much as possible or to maximize the benefits. In this article is mentioned the problematic of transfer pricing and arm´s length principle with connection of CCAs, CSAs. Next, there is mentioned how to settle participation shares of the total cost and benefits contributions with respect to the OECD Transfer pricing for MNEs Guidelines and with respect to other significant regulations.

Number of Pages in PDF File: 22

Keywords: Arm’s Length Principle, Cost Contribution Arrangements, Cost Sharing Agreements, Reasonable Anticipated Benefits, Relevant Costs, Transfer Prices

JEL Classification: G39, M40, H25, D21

working papers series